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BLOOMBERG v. COMMISSIONER

Docket No. 2977-78.

74 T.C. 1368 (1980)

LEROY BLOOMBERG AND SALLY BLOOMBERG, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 23, 1980.

Attorney(s) appearing for the Case

David M. Buda, for the petitioners.

Charles M. Layton, for the respondent.

DRENNEN, Judge:

Respondent determined a deficiency in petitioners' income tax for the year 1974 in the amount of $6,849.33. Due to concessions of the parties, the only issues for decision are (1) whether petitioners are entitled to an investment credit under sections 38 and 46, I.R.C. 1954, for equipment owned by petitioners and leased to petitioners' professional corporation, Leroy Bloomberg, M.D., Inc., and (2) whether

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